April 22, 2026

U.S. Customs and Border Protection (CBP) has launched Phase 1 of its Consolidated Administration and Processing of Entries (CAPE) system, providing a pathway for importers to begin recovering duties paid under the International Emergency Economic Powers Act (IEEPA).

While the process is now active, it is important to understand that Phase 1 is limited in scope, highly controlled, and designed for speed—not completeness.

1. The Filing Process Is Simple—By Design

Phase 1 CAPE submissions are made through the ACE portal using a CSV upload.

At this stage, the required format is minimal:

• One column: Entry Number

• One entry per row

• No additional data fieldsrequired

CBP is pulling all supporting entry data internally from ACE, including classification, value, and duty payments.

Important:Once a CAPE declaration is accepted, it cannot be amended. Additional entries must be submitted in a new declaration.

2. Phase 1 Eligibility Is the Real Filter

The simplicity of the filing format does not eliminate the need for careful entry selection.

Phase 1 is currently limited to:

• Unliquidated entries, and

• Recently liquidated entries within CBP’s operational reliquidation window (approximately 80–90 days)

Entries generally excluded from Phase 1 include:

• Finally liquidated entries

• Entries under active protest

• Entries flagged for reconciliation or drawback

• AD/CVD-suspended entries pending Department of Commerce instructions

These exclusions are operational decisions by CBP and do not necessarily reflect the full scope of relief contemplated by the courts.

3. Not All Refunds Are Covered in Phase 1

Phase 1 is expected to cover a majority of eligible entries, but not all.

Importers should anticipate that:

• A meaningful portion of entries—particularly older or more complex filings—will fall into later CAPE phases or require resolution through other mechanisms

• Larger dollar exposures may be concentrated in categories not yet included in Phase 1

CBP has indicated that additional phases will follow, but no timeline has been confirmed.

4. Refund Timing and Payment Mechanics

CBP has advised that refunds will generally be issued within 60–90 days of declaration acceptance, subject to compliance review.

Refunds will be processed through existing ACH payment setups in ACE.

Importers should also be aware:

• Refunds may be offset against outstanding duty obligations, where applicable

5. Strategy Matters: Prepare, Then Proceed

Given the structure of Phase 1, importers are advised to:

• Confirm ACE account readiness, including ACH enrollment and account control

• Compile a validated list of entry numbers

• Segment entries into:

  • Phase 1 eligible

  • Likely Phase 2 or later

• Begin with a small test submission before scaling

  
  

Practical guidance:

• If you are unsure how to proceed, consult your forwarder or a trusted advisor

• Focus on accuracy over speed—errors cannot be corrected after submission

• If your company does not yet have access to its ACE Importer account, your forwarder can submit CAPE declarations on your behalf for entries they handled

The CAPE process is straightforward at the surface, but submission accuracy and eligibility discipline are critical.

6. Key Takeaway

Phase 1 of CAPE is best understood as:

A targeted entry selection and recalculation system, not a full claims process.

Importers who can quickly identify and validate eligible entries are positioned to recover a substantial portion of duties early in the process.

Hobby Industry Coalition Note

The Hobby Industry Coalition continues to monitor CBP implementation and court developments closely. Further updates will be provided as additional CAPE phases are defined.

Disclaimer:
This information is believed to be accurate as of the date above and is provided for informational purposes only. It does not constitute legal, financial, or business advice. Readers should independently verify details and consult appropriate advisors before taking action.